…of the North Sea. At the time, licences for this activity were only issued to UK resident companies. The common practice at the time was for non-resident companies to enter…

…omission of a formal compliance requirement (notably, sending a monthly declaration to the Italian Customs Agency) does not preclude the application of a subsidized tax regime, given the objective nature…

…paid dividends and attending fees to its Luxembourgish parent company. Apart from other investments, the Luxembourgish shareholder held around 9.5% in the stake of the Spanish company, which in Spain…